Grounds considered for reducing the penalty :
👉 No business income during the period of default
👉 Other income was only notional income on OFCD
👉 Interest on OFCD not paid till repayment of entire term loan
👉 No fund available to pay remuneration to CS as per the market standards
👉 Appointment of whole time company secretary in July 2017 (Vacant since Dec 2014)